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Like most property buyers, you may have been saving up all your life to finally buy your first one bedroom apartment. And now that you are about to fulfil your dream, your real estate agent is asking several questions: how you managed to put that sum together, what is your job, whether you inherited any money, whether you have multiple jobs, etc! You may be wondering why they are asking all the questions you would expect your bank to be asking. The simple answer to this question is that estate agents are subject to the same Anti-Money Laundering and Funding of Terrorism (AML / FT) regulation that a bank is subject to.

Real estate agents facilitate transactions involving the transfer of high value items (in this case properties) between parties and the resulting movement of money. These high-value transactions are susceptible to money laundering because the movement of large amount of money could be used to turn funds that were earned illicitly into clean funds. How is this possible?

Let’s consider the following scenario:

Mr. X has made a large sum of money by acting as a middle-man in a large transaction involving the trafficking of illegal substances. Now Mr. X is sitting on €500,000 which he would like to spend, hopefully without attracting the attention of the tax authorities. Mr. X really wants to buy the latest Maserati. If he tries to do this with the income he actually declares from the sales he makes through his portable hot dog stand, he may raise the attention of the Tax Compliance Unit who would ask how could he afford a luxury car. As always, Mr. X has a devious plan to launder some money, and he does it in the following manner:

Obviously the above requires some tact and manipulation, however when it comes to the extent that criminals are willing to go to launder the proceeds of their illegal activities, it is definitely not far-fetched.

This case explains one of

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